Federal (Canada) privacy & access decisions

A life insurance company discovered that a mass mailing error risked exposing the personal information of 53 pension plan members. The new window envelopes used were larger, potentially revealing certificate numbers, SINs, dates of birth, spouse's names, and beneficiaries if statements shifted. Upon discovering the incident, the company promptly notified affected individuals, apologized, explained the incident, and offered a free one-year credit monitoring service. They also advised members to take harm-reducing steps and ceased using the problematic envelopes. The company informed the OPC about the incident and its response. The OPC concluded that the company demonstrated best practices in its incident response.

• Whether a mass mailing error led to the potential exposure of personal information
• Whether the life insurance company's response to the incident constituted best practices

An individual complained that her bank required the last six digits of her Social Insurance Number (SIN) to set up a "verified credit account" for online purchases. She believed this practice was inappropriate and that an alternative method not requiring SIN information should be available. The bank initially stated an alternative existed through commercial websites, but the complainant noted this was not clearly communicated. The OPC highlighted a comparable case where a lack of transparency regarding authentication alternatives was found. Following this, the bank decided to discontinue the SIN-based authentication method entirely and update its website. The complainant was satisfied with this resolution, and the OPC confirmed the website changes.

• Whether collecting a partial SIN for credit card account verification was appropriate under PIPEDA
• Whether the bank provided adequate transparency regarding alternative verification methods